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Decision A.1147/2026 issued by the Independent Authority for Public Revenues simplifies the procedure for inclusion in the alternative taxation regime for foreign-source income under Article 5A of Law 4172/2013. The regime applies to individuals residing outside Greece and contemplating to transfer their tax residence to Greece while making a qualifying investment in Greece. For the enhanced facilitation of taxpayers, the application and accompanying documentation may be submitted either digitally, by post or in person.
- Applicants may submit their request by:
a. 30 September of the year of arrival, for inclusion under Article 5A effective in the same year.
b. 30 September of the following tax year, for inclusion under Article 5A effective in the year following their arrival in Greece. - Individuals transferring their tax residence to Greece:
a. up to 2 July of a given year may elect inclusion either for the year of arrival or for the subsequent year.
b. After 2 July may only apply for inclusion with effect from the tax year following their arrival. - Supporting documentation completing the application file may be submitted no later than 31 October of the tax year for which inclusion is requested.
- The taxpayer may request the extension of the alternative taxation regime to related persons (spouse, parents, children), either with the initial application or at a later stage.
- The decision of the Tax Administration on the respective application is issued by the last working day of November.
- The tax is payable annually by the last working day of December and upon its full payment, all tax obligations relating to foreign‑source income are exhausted.
The new provisions apply to:
1. new applications (submitted after 25 June 2026);
2. applications pending on 25 June 2026; and
3. assessment acts determining the lump-sum tax for the 2026 tax year, for which the tax was due at the time the decision entered into force (20 July 2026).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.